In January 2020, the US Department of Health and Human Services (HHS) included oral fluid testing in mandatory guidelines for federal workplace drug testing programs. As employers await any official implementations, small changes such as those to Custody and Control Forms (CCFs) are beginning to make their presence. Currently, lab-based urinalysis testing still remains the only approved testing by the DOT, but a box to check for oral fluid testing has most recently appeared on CCFs.
Even though this change has been made on the forms, oral fluid testing is still pending implementation, which is why it’s so imperative that employers remain up to date. Although there’s a standard implementation period between 12-18 months allowing those under federal regulations to choose lab-based oral fluid testing as an alternative to, or add it to, a traditional urine or hair-based testing program, as of October 1, 2020, there are currently no HHS certified labs approved for oral fluid testing.
Transition to a New DOT-Regulated CCF
In addition to adding oral fluid (saliva) testing to the DOT-regulated CCF, the new form also added Commercial Driver’s License (CDL) state and number. The inclusion of the CDL number and state of issuance here will significantly assist medical review officers. After August 30, 2021, use of this new CCF will be required. Failure to transition to the new form by the cutover date of August 30 may result in tests being rejected. It is highly recommended employers immediately transition to the new CCF forms to avoid issues and discard any remaining old forms.
What Does This Mean for Employers?
Although the guidelines are currently pending for federally mandated employees only, oral fluid drug testing is beneficial across all job sectors, especially when combined with another drug testing method. For example, oral fluid and urine or hair-based testing can be used for pre-employment, random, reasonable suspicion, post-accident, return-to-duty, and follow-up testing. Many employers who were hesitant about oral fluid testing are now considering it in combination with urine or hair-based drug testing, thanks to the OFMG serving as an official endorsement by the federal government. This type of backing helps employers feel confident that oral fluid testing is accredited and has many advantages for keeping workplaces safe. Even if an employer is not DOT-regulated, by combining testing methodologies, such as a urinalysis with oral fluid, you’ll create a wider detection window as oral fluid detects more recent use, and a urinalysis can provide a longer window.
What Can DISA Do?
As employers eagerly await any oral fluid implementations under the DOT, DISA’s professionals can assist you with creating a drug testing program custom to your company’s needs. With the complexity surrounding marijuana laws and the growing opioid epidemic, employers need to protect both their employees and the workplace. Whether you’re regulated under the DOT or not, it’s vital to implement drug testing standards to help you meet and maintain compliance. Our experts are equipped with the knowledge and skills to ensure you’re meeting best practices.
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About DISA Global Solutions
Founded in 1986, DISA is the industry-leading provider of employee screening and compliance services. Headquartered in Houston, with more than 30 offices throughout the U.S. and Canada, DISA’s comprehensive scope of services includes drug and alcohol testing, background screening, occupational health, and transportation compliance. DISA assists employers in making informed staffing decisions while building a culture of safety in their workplace.